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WRITTEN SUBMISSIONS: WATER SERVICES AMENDMENT BILL [B24 – 2025]
The Centre for Environmental Rights (CER) welcomes the introduction of a licensing regime and personal liability for directors in the Water Services Amendment Bill [B24 – 2025] but warns that the Bill concentrates too much power in the Director General and lacks mandatory environmental and public health standards for licensing. The CER argues that the Bill fails to address systemic under-funding of infrastructure and climate-change resilience, and it calls for the inclusion of mandatory climate-adaptation plans and a national framework for wastewater reuse.
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Document type: Statement
The relevance and reinvigoration of the Women, Peace and Security agenda
The author critiques the Women, Peace and Security (WPS) agenda for its failure to move beyond rhetorical commitments to substantive protection and inclusion. While acknowledging its role in elevating conflict-related sexual violence, the paper argues that the agenda's focus on penetrative rape has occluded other gender-based harms, such as obstetric and structural violence. It further highlights the marginalization of women in formal peace negotiations and the failure to account for colonial causality. The author proposes a shift toward 'everyday peace'—focusing on the long-term, grassroots conditions of survival and tolerance—to ensure a more inclusive and sustainable peace that addresses the needs of all women, particularly those from marginalized ethnic and racial backgrounds.
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Document type: Research paper
Sixth Omnibus on chemicals
ClientEarth and nine other organisations challenge the European Commission's 'Sixth Omnibus on chemicals' proposal, asserting that it introduces dangerous exceptions for carcinogenic, mutagenic, and reprotoxic substances (CMRs) in cosmetics and rolls back hazard communication rules in the CLP Regulation. The briefing contends that these changes violate the EU Charter of Fundamental Rights, fail to genuinely improve EU competitiveness, and were developed without the legally required public consultations, relying instead on industry-dominated workshops.
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Document type: Briefing
The Trump Administration Forces Power Plants to Continue Burning Fossil Fuels
The Department of Energy (DOE) has ordered the J.H. Campbell coal plant in Michigan and units of the Eddystone oil and gas plant in Pennsylvania to remain open, overturning planned retirements. Earthjustice contends these orders are an illegal abuse of Section 202(c) of the Federal Power Act, as there is no evidence of a reliability risk. The document asserts that these actions override state regulators and market decisions to prop up uncompetitive fossil fuels, potentially costing utility customers millions and hindering the transition to clean energy.
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Document type: Statement
The Trump Administration Aims to Gut Critical Habitat Protections for Endangered Species
The Trump administration proposed on April 17 to rescind regulations under the Endangered Species Act (ESA) that prohibit significant habitat modification or degradation. Earthjustice contends that habitat destruction is the primary cause of extinction and that this proposal undermines essential protections for wildlife. The document also notes the administration's interest in using the 'God Squad' committee to waive protections and the Interior Secretary's suggestion that lab-created facsimiles could replace endangered species.
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Document type: Statement
Polluters can now email their way out of clean air laws, courtesy of Trump
The author contends that the Trump administration and EPA Administrator Lee Zeldin are bypassing clean air laws by granting pollution waivers to coal-fired power plants and chemical manufacturers. The document asserts that the administration is distorting Section 112(i)(4) of the Clean Air Act—originally intended for extraordinary national security circumstances—to provide corporate giveaways without scientific review or public input. It highlights that 68 coal-fired power plants have already received two-year exemptions from Mercury and Air Toxics Standards, and that industry groups like the American Chemistry Council are seeking similar exemptions for over 200 chemical facilities.
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Document type: Statement
please-oppose-gulf-biop-provision-in-reconciliation-ed6e3374615c1160.pdf
A coalition of environmental and animal welfare organizations argues that a House reconciliation bill would jeopardize the Rice’s whale by legislating that a 2020 Trump-era Biological Opinion (BiOp) is sufficient for oil and gas lease sales, despite the BiOp being struck down by a U.S. District Court in 2024. The authors claim the bill would allow oil and gas companies to bypass environmental reviews and further weaken existing mitigation measures, specifically those regarding seismic airgun surveys, risking the extinction of the 50-100 remaining Rice’s whales.
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Document type: Statement
Directions for the REACH revision – CARACAL 54
ClientEarth's response to the CARACAL-54 presentation on the REACH revision emphasizes the need to modernize registration requirements, enhance transparency, and maintain the phase-out goal for substances of very high concern (SVHCs). The organization strongly opposes making the Analysis of Risk Management Options (RMOA) mandatory, claiming it would create regulatory bottlenecks and undermine the objective of phasing out hazardous chemicals. Key recommendations include introducing a mixture assessment factor (MAF) of at least 100, expanding the scope of registration to include polymers, and harmonizing sanctions across EU Member States to ensure effective enforcement.
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Document type: Statement
The new State aid Framework to support the Clean Industrial Deal
ClientEarth's response to the CISAF consultation emphasizes the need for horizontal integration of the 'Do No Significant Harm' (DNSH) principle and the removal of aid for fossil gas in industrial decarbonisation. The organization warns that proposed 36-month project completion deadlines may compromise environmental permitting and public participation. It further advocates for stricter conditions on carbon capture and hydrogen aid, suggesting that support be limited to 100% renewable hydrogen and hard-to-abate sectors.
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Document type: Statement
Why Is Investment Treaty and Investor–State Dispute Settlement Reform Needed?
The document examines the failures of traditional investment treaties and the ISDS system, which it argues prioritize investor protection over public interest and sustainable development. It highlights the high financial costs of ISDS awards, the phenomenon of 'regulatory chill' where states avoid necessary environmental or social reforms to avoid litigation, and the lack of investor obligations. The report advocates for a shift toward treaties focused on investment facilitation and cooperation, the termination of outdated agreements, and a coordinated global effort to modernize investment governance.
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Document type: Report
¿Por Qué Es Necesaria la Reforma de los Tratados de Inversión y la Solución de Controversias entre Inversionista y Estado?
The document examines the role of foreign direct investment (FDI) and the legal frameworks governing it, specifically criticizing the ISDS system for prioritizing investor protections over public interest and sustainable development. It details the financial and regulatory burdens placed on states by ISDS awards and advocates for a proactive, holistic reform of investment governance.
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Document type: Report
Pourquoi faut-il réformer les traités d’investissement et le règlement des différends entre investisseurs et États ?
The document examines the role of legal frameworks in governing foreign direct investment (FDI) and critiques traditional investment treaties and the ISDS system. It argues that these frameworks often prioritize investor protections over public interests, creating a 'regulatory chill' and imposing high financial burdens on states, particularly in the context of the energy transition. The guide proposes a shift toward treaties focused on cooperation and sustainable development, while detailing various national, bilateral, and multilateral reform strategies.
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Document type: Guide
Concerns about the inadequate consultation process on the Omnibus Simplification Package
ClientEarth and a coalition of civil society organizations argue that the European Commission's 'Omnibus Simplification Package' is being developed through an opaque, non-inclusive process that violates EU democratic principles and the Commission's own Better Regulation Guidelines. The authors contend that the Commission is facilitating 'regulatory capture' by prioritizing private meetings with industry actors over broad public consultation, potentially undermining the Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD). They demand a comprehensive impact assessment and a public consultation involving all relevant stakeholders before any legislative proposal is presented.
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Document type: Statement
El ‘Escuadrón de Dios’: Este Comité es Sólo el Comienzo de los Ataques de Trump contra las Especies en Peligro de Extinción
The briefing warns that the Trump administration is attempting to weaken the Endangered Species Act (ESA) by empowering a presidential committee, referred to as the 'God Squad,' to prioritize development and special interests over the survival of endangered species. Earthjustice asserts that the ESA is a critical tool for combating the biodiversity crisis, noting that over one-third of U.S. flora and fauna are at risk. The organization highlights its history of successfully challenging Trump-era rollbacks in court and maintains that legal, scientific, and economic findings must precede any committee decision to remove species protections.
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Document type: Briefing
Briefing Paper Kaleidoskop 2025 Bencana Iklim Kian Masif, Akankah Pemerintah Berhenti Menggunakan Energi Fosil di Tahun 2026?
The document details the legal actions taken by a coalition of civil society organizations, including Trend Asia, WALHI, and Greenpeace Indonesia, against the Indonesian government's National Electricity General Plan (RUKN) and the Electricity Supply Business Plan (RUPTL). It argues that these plans ignore the escalating climate crisis—exemplified by Cyclone Senyar—and instead lock the country into fossil fuel dependency through the extension of coal-fired power plants (PLTU) and the use of biomass co-firing, which the authors claim drives deforestation. The coalition alleges that these policies violate multiple national laws and international commitments, such as the Paris Agreement, by failing to provide a clear coal phase-out roadmap and ignoring cheaper renewable energy alternatives.
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Document type: Briefing
Initial Reactions to Chair of the Intergovernmental Negotiating Committee’s Third Non-Paper
The document argues that the Chair's third non-paper provides an adequate structure for negotiations at INC-5 but would result in an 'ineffective and useless treaty' if not significantly strengthened. CIEL advocates for replacing voluntary language with legally binding obligations, establishing a dedicated financial mechanism based on the polluter pays principle, and implementing global phase-outs of chemicals of concern. Key recommendations include introducing a freeze on new polymer production capacity, making national plans mandatory, and adopting a qualified majority voting system for the Conference of the Parties to prevent decision-making paralysis.
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Document type: Briefing
International Investment Law and ISDS: Overcoming Legal Barriers to Effective Climate Action under the UNFCCC and the Paris Agreement
The document examines how ISDS allows foreign investors, particularly in the fossil fuel industry, to sue governments over climate regulations, leading to a 'chilling effect' where states delay or weaken policies to avoid costly awards. It argues that these protections act as a subsidy for GHG-intensive industries, contradicting Article 2.1(c) of the Paris Agreement. The brief concludes that fragmented procedural reforms are insufficient and advocates for a unified global approach, including the use of COP29 and Nationally Determined Contributions (NDCs) to coordinate ISDS withdrawals or carve-outs.
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Document type: Policy brief
Labour must end criminalisation of climate protesters
Global Witness criticises the UK's crackdown on climate activists, citing the four-year prison sentence of Daniel Shaw and the use of the Public Order Act 2023 and the Police, Crime, Sentencing and Courts Bill 2022. The organisation highlights that over 7,000 climate protesters have been arrested since 2019 and argues that the fossil fuel industry has influenced the legislation used to muzzle defenders. It calls on the new Labour government to protect the right to peaceful protest.
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Document type: Statement
Directive sur le devoir de vigilance : une occasion manquée pour la finance
The CSDDD requires large companies to ensure their operations do not have disproportionate impacts on the climate, environment, biodiversity, and human rights. However, the document highlights a critical gap: financial services are excluded from due diligence requirements, meaning financial actors are only responsible for their non-financial activities (e.g., office supplies) rather than their investments in harmful projects. While the directive mandates climate transition plans for all covered entities, including financial actors, the document warns that relying on CSRD reporting standards may result in low-quality, non-prescriptive plans that fail to stop fossil fuel expansion.
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Document type: Statement
NATURAL JUSTICE COMMENTARY ON THE INTEGRATED RESOURCE PLAN 2023
Natural Justice argues that the IRP2023 is a regression from previous plans and lacks a proper legal basis, as it functions as a policy instrument rather than an operational plan. The organization contends that the IRP2023 incorrectly prioritizes energy security over other national policy objectives like affordable access and environmental sustainability. It calls for the adoption of an Energy Justice Framework to address the rights of indigenous peoples and local communities, particularly regarding land, water, and gender equality, and recommends the development of a comprehensive Integrated Energy Plan (IEP) as mandated by the National Energy Act.
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Document type: Report